Fracking for shale gas and oil is one of the most controversial environmental issues facing the UK. The process involves drilling a well into rock formations thousands of metres below the Earth's surface. Huge amounts of water and a cocktail of often-toxic chemicals are pumped in at high pressure to fracture the rock and release the gas.
Please Do This before the 16 July
This is the short public consultation that MUST be responded to – or there will be little to stop a wholesale industrialisation of swathes of the UK landscape and associated health issues (like poisoned drinking water).
Please then SHARE this document with EVERYONE – not just people who live in Sussex.
This document is provided in good faith by NoFiBS (No Fracking in Balcombe Society) to guide you when making a response to the current consultation. You are of course free to say what you like when you respond.
Your own thoughts are most important, and your own words will make more impact.
What is a Mining Waste Permit?
It is a permit for the management of waste extracted (in our case) during prospecting for oil and gas. Cuadrilla have been obliged to apply to the Environment Agency (EA) for a Mining Waste Permit for their Balcombe site, this in addition to permits they had been granted previously. To issue the permit, the EA decide whether Cuadrilla Balcombe Limited have shown that the environment will be protected and human health will not be harmed. They are obliged to consult the public – hence the one month delay in drilling.
Why is it important I respond?
This is the first time outside the original planning application in 2010 that the public has been consulted. Therefore, whatever your concerns or questions about the waste, emissions and impact on health and the environment, it is really important that you respond. Please also ask your neighbours, local school, doctors and organisations to respond too.
Responding to the Consultation:
It is preferable when writing your comments that you phrase everything as a question not a general statement.
Alternatively, you could create a statement and then pose questions about it: How, Why, When, Where, What, Who?
This information is intended to help you formulate your own questions – a response in your own words will make a much stronger impact - and take more time for the EA to respond to - than someone else’s identical template.
The information is guidance only and is not really a substitute for reading through the 14 permit documents.
However if that is a bit daunting, and you don’t know where to start, what follows should be a good starting point!
Click the link and then the ADD COMMENTS button, and feel free to use the focused questions below – though make them ‘your own’ if you can.
The waste management plan is full of rhetoric, subjective phrases, cliches and unquantified terms. Please see below a list of examples taken from the Waste Management Plan:
• ‘every effort’ – Completely meaningless and unmeasured. Assumes the company is acting for public good rather than private profit. In reality the purpose of Cuadrilla, privately owned and financed, is to maximise returns and profit to shareholders by reducing costs wherever possible.
• ‘minimal discharge’ – Again completely unmeasured. The scope of interpretation of ‘minimal’ is huge. I do not agree to any ‘minimal’ discharges
• ‘wherever possible’ – OK, so who’s to say it’s possible or not possible. The bounds of ‘possibility’ are completely subjective and depend on the company’s view to risk, likely financial penalties, insurance etc. If they believe they can off-set fines for environmental pollution on their insurers etc they will and ‘possible’ will become ‘impossible’.
• ‘competent contractor’ – Surely, every contractor is deemed competent until something goes wrong.
• ‘small’ – referring to amounts of pollution. Again, a subjective opinion. This does not tell me anything about quantity.
• ‘highly likely’ – Referring to extraction of spent hydrochloric acid waste. If it’s highly likely to be fully extracted, by definition it means there is a possibility that it will not be fully extracted. Not good enough. This leaves leeway for the company leave waste hydrochloric acid waste. No thanks..
• ‘low risk’ – An unmeasurable and undemonstrable level of risk which is purely subjective and depends on your degree of risk aversion. Q2 Please see above
Q2. Having studied the Waste Management Plan, the Environmental Risk Assessment and the Site Condition Report, I do not agree that Cuadrilla have demonstrated they will not cause harm to the environment. I believe the opposite. I believe they demonstrate there will be environmental harm, pollution and emissions. The plan demonstrates clearly how impossible it is to make Cuadrilla’s proposed activity environmentally safe. The Site Condition report acknowledges the drilling site is WITHIN an Area of Outstanding Natural Beauty, and is very close, within metres of three Local Nature reserves with protected species and within metres of designated areas of ancient woodland. Two open streams that carry water to Ardingly reservoir are within metres of the drilling site. Please see
Q3. Having studied the Waste Management Plan and the Environmental Risk Assessment, I do not agree that Cuadrilla have demonstrated they will not cause harm to human health. They clearly show there will be airborne pollution. I do not accept this does not cause harm to human health. Cuadrilla have also not been able to say they will be able to recover all the waste hydrochloric acid wash they will use. They have not been able to show they will recover all the contaminated drilling muds. Cuadrilla’s plans demonstrate clearly there will be damage to human health.
Yes, I believe Cuadrilla have failed to address the following: The damage to the public perception of Sussex being a rural and green non-industrialised protected and defended landscape. This perception is critical for upholding local economic factors such as tourism and house prices.
A review of the Waste Management Plan and Environmental Risk Assessment show that Cuadrilla’s measures to prevent accidents and limit their consequences are completely unconvincing:
• ‘visual inspections’ – Undefined activity. A visual inspection would most likely not be nearly sufficient to detect any pollution or emissions.
• ‘pollution incident plan’ – Insufficient information to make a judgement on efficacy.
• ‘spill kits available’ -Insufficient information to make a judgement on efficacy. This sounds insubstantial and totally insufficient to prevent fugitive emissions of methane gas.
Q6 Please take into account Cuadrilla’s history of accidents and mal-practice in other areas of the country, namely Lancashire. Please also consider the nature of the industry itself. This form of mineral exploitation is known as ‘extreme energy recovery’. Please consider that this kind of industrial activity is not suitable in a landscape of this calibre and heritage as we find in Sussex. From an environmental perspective I do not consider it appropriate to allow exploitation of this protected landscape, with both European and UK national designations. The environmental costs and social and economic costs to Sussex will outweigh any economic benefits. Cuadrilla’s activities have been shown to be inherently risky. This ‘extreme energy recovery’ industry is by nature risky and dangerous. In full swing the industrialised processes use dangerous chemicals and squanders thousands of litres of clean water, creates dangerous radioactive fluid wastes and causes airborne pollution from VOC’s oxides of nitrogen and sulphur, dioxins, heavy metals and polycromatic carbons. Please consider the above. Please draw a line. Please say NO now. Otherwise, before we know it, they will be in by stealth and we will be faced with fracking activity, destruction and pollution of water, land, air, life and communities I trust you know the dangers of fracking from the devastation this industry has caused elsewhere. Do we need any more convincing evidence to say this industry is dangerous and completely unfit for operation in Sussex? I think not. Environment Agency, please show your teeth!
This is a small point - apologies for being overly fussy - if you are like me copying and pasting the above responses (thank you for making it easy for me!), please make sure that Cuadrilla is spelled correctly!
have I spelt it wrong?
Yes, in some sections you've written Caudrilla instead of Cuadrilla. Worth correcting, as Jen says, for all us copy&pasters...
Thanks for all your good work on this Mike!
thanks - text edited and the spelling (hopefully) all corrected
• Water - Groundwater, surface water, drilling through the aquifer, proximity to local gill streams which flow into the River Ouse and finally to Ardingly Reservoir. The site falls in a designated EA drinking water protected area.
These are all at risk from contamination from the chemicals Cuadrilla will be using and the flowback fluid (the liquid effluent that comes back out of the well back to the surface). How will they be protected?
• Air Pollution - The new 13.7m flare is a very different proposition to the 1.6m ground flare for which Cuadrilla originally had planning permission, both in impact, scale, noise and light – How will human health be protected from these emissions?
How will the emissions be reported to the general public? The documentation says that flaring will happen for one week – what happens if it is more than this? Who is monitoring it?
• Ecology and Surroundings – The site falls in an Area of Outstanding Natural Beauty. Rare and protected species such as bats, water voles great crested newts and returning red kites - as well as rare lichens have been confirmed within 2km of the site. The site is bounded by ancient woodland, where the original environmental searches cited bats – how will these important fauna and flora be protected?
• Noise and Odour – Who will be ensuring that the noise levels do not exceed those set down in the planning conditions? What odour might there be?
• Regulation – Cuadrilla Balcombe will be hiring many subcontractors - who is permitting and controlling them?Will they be regulated and controlled by the permit?
How will the EA be monitoring the extractive waste and operations onsite to ensure that the environment and human health will not be harmed?
What happens when the planning approval and the mining waste documentation do not match?
What happens when a new planning application is submitted? Will the permit be transferred to the new application?
Who will ensure that there is enough time to complete operations before the drilling starts?
• Waste Cuttings and Fluids – the fluid that comes back out of the well is called flowback fluid. It is extractive waste controlled by the permit.
Where will that waste be stored? How long will it remain there? How will it be disposed of and transported? Where will it be transported to? How will it be treated? When will the resulting liquid be disposed of? What happens if there is a spill or an accident on the road?
How will the environment and human health be protected from this flowback fluid?
• Emergency Planning – worst case scenario: a spill, a blow-out?
What plans are in place for evacuation and safety of the residents of Balcombe? What emergency services are on standby, and given that the site is within 40m of a mainline trainline, what procedures will Network Rail follow?
If people smell odours from the site in the village what should they do?
• Aftercare - When the well has been abandoned, who will be monitoring it and for how long?
More Ideas for Action from Frack Free FRow
One of the reasons the Australian Street Teams were so successful is because they got their local mayor on board. Having the support of local, regional and national decision-makers is vital. We have voices that we can make heard with the opinion leaders and decision makers, at a national level. Writing a letter carries a big weight and, if enough of us write, there is a chance we can create enough momentum for an independent national enquiry into the risks of fracking.
You could write to:
· Your MEPs
Let’s ask these questions at a European level. There are quite a few MEPs covering our area. To find one to write to go to http://www.WriteToThem.com
One of the biggest, tangible risks with fracking is permanent pollution of underground water supplies – aquifers – as well as pollution of reservoirs and the disposal of the ‘Produced Water’ (I.e. Highly contaminated fracking by-products). Wouldn’t it be great to have our local water board explaining what actions they are taking, to make sure our water supplies cannot possibly be contaminated? Especially since the water company is planning to increase the use of bore holes to supply our water in coming years because we don’t have enough water as it is – just the supplies that are most at risk from fracking problems? How are they going to maintain adequate water supply for customer usage, if the fracking processes are using so many millions of additional litres? Water is already a scarce resource.
Gordon Maxwell, Chairman, Southeast Water, Snodland, Kent. ME6 5AH
· Department Of Energy And Climate Change
These are the people who are telling us we need to be using fracked gas and oil, for our future energy needs. If enough of us write to them, we can make a difference.
Simon Toole: Head of Exploration, Licensing & Development ~ Simon.Toole@DECC.GSI.GOV.UK ~ 3 Whitehall Place, London SW1A 2AW
· Minister Of State For Energy
Michael Fallon: Michael.Fallon.MP@Parliament.uk ~ Michael Fallon, House of Commons, London, SW1A 0AA
Top Tips For Your Letters
1. By all means use a template (thank you to Roger and his team at http://www.weekly-letter.co.uk), but please adapt it to be in your own words and to make your own points. It carries so much more weight than one which is ‘copied and pasted’.
3. Write from a place of love, hope and strength, not anger and fear – it makes a huge difference.
4. Ask questions, rather than telling them what to think. Ask for their opinion. Ask what steps they are taking to make sure that there is zero risk to our environment, air quality or water quality as a result of either exploratory drilling or full-scale fracking.
5. Ask for an independent national enquiry into the risks of fracking, before any more permits are granted.
Any Other Ideas?
· Could you ask your employer to circulate the Environment Agency public consultation (and guidance notes) to all members of staff?
· Could you get your school involved in the children writing to their MP / the Minster Of State For Energy?
· Could you go to Lewes this weekend to watch the play they have written about fracking?
· Could you spread the word to your friends and loved-ones? Via email? Via Facebook?
· If you have any other ideas of how we can raise awareness about fracking, to allow people to make an informed choice and hopefully inspire them to take action, please share them at https://www.facebook.com/FrackFreeFrow or https://www.facebook.com/FrackFreeSussex
Thank you so much! Each and every letter makes a difference.
Hi Mike This link has a good article about fracking (2nd article down) Shale Is A Pipedream Sold To Greater Fools